Privacy Policy

ZUG Commodities ("we," "us," or "our") operates the website zugcommodities.com (the "Service"). This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you visit our website. We are committed to protecting your privacy in compliance with the Swiss Federal Act on Data Protection (FADP/nDSG), the European Union General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA).

1. Data Controller

The data controller responsible for your personal data is:

ZUG Commodities
Vevey, Canton of Vaud
Switzerland
Email: privacy@zugcommodities.com

2. Information We Collect

2.1 Automatically Collected Data

When you visit our website, we automatically collect certain information through cookies and similar technologies:

• IP address (anonymized where required by applicable law)
• Browser type and version (e.g., Chrome 120, Safari 17)
• Operating system (e.g., Windows 11, macOS Sonoma, iOS 18)
• Referring/exit pages and URLs
• Pages visited, time spent on each page, and click behavior
• Date and time of access
• Device type (desktop, tablet, mobile) and screen resolution
• Geographic location (country/region level, derived from IP address)

2.2 Voluntarily Provided Data

When you use our contact form or subscribe to communications, we may collect:

• Name
• Email address
• Subject and message content
• Any other information you voluntarily provide

3. How We Use Your Information

We use collected information for the following purposes:

• To operate, maintain, and improve the website and its content
• To analyze user behavior and optimize user experience
• To respond to inquiries submitted through our contact form
• To display relevant advertising through Google AdSense
• To detect and prevent fraud, abuse, and security incidents
• To comply with legal obligations under Swiss and applicable international law

4. Cookies & Tracking Technologies

4.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. They are widely used to make websites function efficiently, provide analytics data, and enable advertising personalization.

4.2 Types of Cookies We Use

• Strictly necessary cookies — Required for basic website functionality (e.g., cookie consent preference storage). These cannot be disabled.
• Analytics cookies (Google Analytics) — We use Google Analytics 4 (GA4) to understand how visitors interact with our website. GA4 collects anonymized data about page views, session duration, bounce rates, traffic sources, and user demographics. Google Analytics may set cookies including _ga, _ga_*, and _gid.
• Advertising cookies (Google AdSense) — We use Google AdSense to display advertisements. Google and its advertising partners use cookies to serve ads based on your prior visits to this website and other websites. Advertising cookies may include those from Google (e.g., IDE, ANID, NID) and third-party ad networks.

4.3 Google's Use of Cookies

Google uses cookies to serve ads based on your prior visits to our website and other websites. Google's use of advertising cookies enables it and its partners to serve ads based on your browsing patterns. You may opt out of personalized advertising by visiting Google Ads Settings. For more information about how Google uses data when you use our site, please visit Google's Privacy & Terms.

4.4 Managing Cookies

Upon your first visit, you are presented with a cookie consent banner allowing you to accept or decline non-essential cookies. You may also manage cookies through your browser settings. Note that disabling cookies may affect your experience on our website.

5. Third-Party Services

We use the following third-party services that may collect and process your data:

• Google Analytics 4 (GA4) — Website analytics. Privacy policy: policies.google.com/privacy
• Google AdSense — Programmatic advertising. Privacy policy: policies.google.com/privacy
• Google Fonts — Typography delivery. Google may log access to font files. Privacy policy: policies.google.com/privacy

6. Your Rights Under GDPR

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have the following rights under the GDPR and equivalent legislation:

• Right of access — You may request a copy of the personal data we hold about you.
• Right to rectification — You may request correction of inaccurate or incomplete data.
• Right to erasure ("right to be forgotten") — You may request deletion of your personal data, subject to legal retention requirements.
• Right to data portability — You may request your data in a structured, commonly used, machine-readable format.
• Right to restriction of processing — You may request we limit how we process your data in certain circumstances.
• Right to object — You may object to processing based on legitimate interests, including profiling for direct marketing purposes.
• Right to withdraw consent — Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact privacy@zugcommodities.com. We will respond within 30 days.

7. Your Rights Under CCPA

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA):

• Right to know — You may request disclosure of the categories and specific pieces of personal information we have collected about you.
• Right to delete — You may request deletion of personal information we have collected from you, subject to exceptions.
• Right to opt-out of sale — You may opt out of the "sale" of your personal information. Note: We do not sell personal information in the traditional sense. However, the use of advertising cookies may constitute a "sale" under CCPA's broad definition.
• Right to non-discrimination — We will not discriminate against you for exercising your CCPA rights.

To exercise CCPA rights, contact privacy@zugcommodities.com or use the cookie consent mechanism on our website.

8. Data Retention

We retain personal data only as long as necessary for the purposes described in this policy:

• Analytics data — Google Analytics data is retained for 14 months, after which it is automatically deleted.
• Contact form submissions — Retained for 24 months from the date of submission, then deleted unless an ongoing correspondence exists.
• Cookie consent preferences — Stored in your browser's localStorage indefinitely, or until you clear your browser data.
• Server logs — Retained for 90 days for security and diagnostic purposes.

9. International Data Transfers

Your data may be transferred to and processed in countries outside Switzerland and the EEA, including the United States (where Google's servers are located). Such transfers are conducted under appropriate safeguards including Standard Contractual Clauses (SCCs) adopted by the European Commission and/or the Swiss Federal Data Protection and Information Commissioner (FDPIC). Google LLC participates in the EU-U.S. Data Privacy Framework.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including HTTPS encryption for all data in transit, secure hosting infrastructure, access controls, and regular security reviews. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

11. Children's Privacy

Our website is not directed to individuals under the age of 16. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child under 16, we will take steps to delete such information promptly.

12. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be communicated through a prominent notice on our website. The "Last updated" date at the top of this page indicates the most recent revision.

13. Contact

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact:

ZUG Commodities — Data Protection
Email: privacy@zugcommodities.com
Vevey, Canton of Vaud, Switzerland

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or, for EEA residents, with your local supervisory authority.